Regulation of leased federal airports in Australia

Transcription

1 Regulation of leased federal airports in Australia With a focus on contaminated sites Presentation for International Committee On Contaminated Land

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3 History of Australian airports 1996 decision to privatise Australian airports Leased 50yrs, option for a 49yr extension The Airports Act 1996 on 9 October 1996 Nineteen leased federal airport have an Airport Environment Officer (AEO) Airports (Environment Protection) Regulations 1997 commenced in December 1998

4 Airports Act 1996 Section 71 Defines the contents of a Master Plan which includes a 5 year Airport Environmental Strategy (AES) Areas identified as environmentally significant Source of environmental impact of airport operations Measures to control or reduce the impact of operations Studies, reviews and monitoring of impacts Airport Lessee Company s Environmental Objectives

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6 Airports (Environment Protection) Regulations General Duty to Avoid Polluting stormwater pollution control devices 6.01 All existing pollution to be reported 6.02 All pollution present in soil, air, or water is monitored 6.03 Annual environmental report 6.04 If monitoring discloses pollution, airport must provide a report within 14 days to the AEO Airport must keep an environmental site register

7 AES Sources of Env Impact Env Site Register Env Monitoring Env Objectives Compliance Program Aviation Activities Contaminated Noise Management Regulatory Non Aviation Sites Register Air Plans Airport Management Stormwater Soil and GW Haz Substances Energy Waste Biodiversity Land and Heritage

8 AEO role Develop a strong relationship with their airport Review the Airport Environment Strategy and oversee implementation Review Annual Environmental Report Review monitoring, site investigations and remedial reports

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10 AEO role cont.. Review strategies and management plans e.g. stormwater quality management plans Advise airport and Airport Building Controller on environmental aspects of building activities

11 Contaminated sites Airports can have a number of contaminants TCEs, Hydrocarbons (DNAPL, LNAPL), heavy metals, PCBs, BTEX and PAHs Emerging contaminants such as perfluorinated chemicals (e.g. PFOS, PFOA)

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13 Emerging contaminants PFOS is listed under the Stockholm Convention not yet ratified by Australia DoIRD working with a number of stakeholders including Department of Defence, Airservices Australia, Department of Environment, and CRC Care to develop national guidelines

14 Emerging contaminants cont. Interim standards for PFOS and PFOA are being developed by Department of Environment DoIRD has prepared advice for airports on DoIRD has prepared advice for airports on the management of PFCs which may be encountered during building activities

15 Emerging contaminants cont. Airservices Australia and DoIRD procured services of GHD to develop a PFC contamination strategy The strategy was developed to inform the Department of Environment s policy development process This document has been made available to leased federal airports for consideration The strategy can be used as a reference for the airports - it is not a guideline or policy

16 PFCsInterim Contaminant Management Strategy and Decision Framework Peter Nadebaum Senior Principal Environment GHD Pty Ltd

17 The problem Aqueous film-forming foams (AFFF) have been used for firefighting purposes at airports around Australia for decades. These contained perfluorinated or polyfluorinated compounds (PFCs), particularly PFOS and PFOA Use of products containing these compounds has now stopped Soil and groundwater contamination by PFCs remains present in the vicinity of fire training areas, and at low concentrations outside of fire training areas In the absence of guideline levels - ad hoc approach, difficult to make decision on what needs to be done even if trace levels serious restriction on infrastructure works

18 The response Develop an Interim Contamination Management Strategy and Decision Framework for PFCs as input to Department s development of policy for Federal airports for dealing with PFC contamination Provide practicable, risk-based contamination management solutions Take into account guidance being developed by CRC CARE

19 Observations Typical concentrations at fire training grounds: Soil: PFOS <LOR mg/kg, PFOA <LOR 3 mg/kg Groundwater: PFOS up to 900 µg/l, PFOA up to 150 µg/l Also can be detected elsewhere outside fire training grounds, but at low concentrations, eg generally soil PFOS < 1 mg/kg Also present in sediments in drainage lines and receiving water Moderately soluble, long half lives in water (PFOS >41 years, PFOA >92 years, at 25 o C) Readily partition between water and organic rich sediments/soils Bioaccumulation a particular issue (e.g. fish in receiving waters)

20 Guidance particularly required for managing Federal airports Construction activities requiring excavation and management of PFC contaminated soil PFC impacted water that may result from interception/extraction of PFC contaminated groundwater, or from surface runoff from contaminated infrastructure Maintenance activities where PFC contaminated sludge is generated (e.g. waterway dredging, groundwater well installation, etc.)

21 Interim Screening Levels for Federal airports (subject to revision)

22 Soil and sediment management approach for Federal airports Key principles for decision making: Protection of human health is paramount Actions should not increase the extent of contamination, or the risk posed by the contamination Effort/resources prioritised to more heavily contaminated areas Actions should not preclude remediation where residual contamination poses unacceptable risk Management options must account for exposure/transport pathways (direct contact, stormwater runoff, vertical percolation to groundwater), and receptors (site workers, offsite users of groundwater, consumers of fish, ecosystem) Soil classified into three categories, based on PFOS and PFOA concentrations

23 Interim soil and sediment management categories PFC soil and sediment waste interim Upper Limits categories Category 1 Material Concentration ASLP (µg/l) 3 (generally low risk material) (mg/kg) PFOS PFOA Category 2 Material (Low risk to human health, potential risk to ecology and waters) PFOS PFOA Category 3 Material (careful management) PFOS > PFOA > NOTES: 1. UK Environmental Agency 2009 ecological investigation level. 2. USEPA Region 4 health screening level for a commercial/industrial land use. 3. Australian Standard Leaching Procedure. 4. Based on USEPA Region drinking water criteria with 100 fold attenuation factor applied.

24 Soil and sediment decision support framework

25 PFC contaminated soil and sediment - management of excavation work Option 1 reinstate to excavated area Category 1, and potentially Category 2 soil and sediment Option 2 place at another location on the site with the same or higher contamination risk profile Category 1 and Category 2 soil and sediment Option 3 onsite containment Category 1, 2 and 3 soil and sediment Option 4 offsite disposal or on/offsite treatment Category 3 A range of considerations apply to all options

26 Soil and sediment decisionbased risk assessment

27 PFC contaminated water management of disposal at airports Conceptual site model considers: Contaminant transport pathways (direct contact, surface water discharge, sewer discharge, vertical percolation to groundwater) Receptors (site workers, consumers of fish, sewerage/stormwater workers, ecosystems) Management options: Option 1 disposal without treatment to surface water, stormwater or sewer Option 2 on-site treatment, prior to discharge to surface water, stormwater or sewer Option 3 onsite containment or offsite treatment Option 4 recharge of water to aquifer Guidance and commentary on considerations provided for each option.

28 PFC contaminated water management options

29 Management of PFC contaminated groundwater conceptual site model Developing a CSM is important to understanding the risks Considers contaminants of concern, sources, transport pathways, receptors and exposure pathway linkages

30 PFC contaminated groundwater management decision process Define risk profile based on: Facility risk (AFFF use) Setting risk (geology, hydrogeology, land and groundwater beneficial uses, natural resource value, sensitive receptors, etc.) Beneficial use risk (impacts of contamination to on and off-site beneficial uses of groundwater)

31 PFC contaminated groundwater management decision process Groundwater management regimes defined by likely impact and risk: High actual impact has occurred (concentrations above interim investigation levels, onsite receptor controlled by third party (e.g. water authority) impacted, onsite and offsite groundwater impacted and beneficial use precluded Medium impacts observed but do not exceed guidelines, offsite receptors not impacted, incomplete data Low no unacceptable risk to on/offsite receptors through absence of source, or as demonstrated by adequate site contamination data

32 PFC contaminated groundwater management decision process

33 PFC groundwater management monitoring response by risk level

34 Concluding comment A practical risk-based response to the PFC problem at Federal airports Will be revised as guidance is developed by CRC CARE and further information is available

35 Acknowledgements CRC CARE Airservices Australia GHD specialists